[sheet: 2022 Billing Rates]
Timekeeper Name | Title / Role | Office | Bar Admissions | Years of Experience | Timekeeper Classification | Standard Hourly Rate — 2022 | Effective Date | Notes
Leonard Cross | Responsible Partner, Tax Department | Philadelphia (1735 Market Street, Suite 3100, Philadelphia, PA 19103) | NY, NJ, DC | 28 | Partner | $1,475.00 | January 1, 2022 | Responsible Partner; leads examination defense strategy, Appeals representation, and client relationship
Sylvia Hartwell | Billing Partner, Tax Department | New York (600 Lexington Avenue, New York, NY 10022) | NY, DC | 22 | Partner | $1,350.00 | January 1, 2022 | Billing Partner; leads international tax controversy practice; client management and billing oversight
Garrett Simmons | Lead Associate, Tax Department | Philadelphia (1735 Market Street, Suite 3100, Philadelphia, PA 19103) | NY | 7 | Associate | $885.00 | January 1, 2022 | Lead Associate; specializes in transfer pricing economic analysis and IRS controversy; IDR response coordination, economic analysis coordination with Whitmore Valuation Group
Leila Nazari | Working Associate, Tax Department | Philadelphia (1735 Market Street, Suite 3100, Philadelphia, PA 19103) | NY, NJ | 4 | Associate | $695.00 | January 1, 2022 | Working Associate; international tax structuring and controversy support; research, document production, Irish coordination with Thornbury & Keogh
Staff Paralegal (Tax Department) | Paralegal | Philadelphia | N/A | Paralegal | $375.00 | January 1, 2022 | Document management, privilege log preparation, IDR production support
Senior Paralegal (Tax Department) | Senior Paralegal | Philadelphia / New York | N/A | Senior Paralegal | $425.00 | January 1, 2022 | Complex document review, coordination of document productions, trial/hearing preparation support
[sheet: Matter Information]
Field | Detail
Firm Name | Calderwood & Harkness LLP
Firm Headquarters | 600 Lexington Avenue, New York, NY 10022
Lead Office for This Matter | 1735 Market Street, Suite 3100, Philadelphia, PA 19103
Matter Number | 1018-00009
Matter Description | IRS Transfer Pricing Examination Defense — Penterra Pharmaceuticals Corp. (TY 2017–2020)
Client Full Legal Name | Penterra Pharmaceuticals Corp.
Client Short Name | PPC
Client EIN | 22-3741856
Client Address | 2200 Independence Boulevard, Princeton Junction, NJ 08550
Client Contact — Tax | Marcus Whitfield, VP, Global Tax
Client Contact — Legal | Deborah Staines, General Counsel
Engagement Letter Date | June 2, 2022
Scope | Defense of IRS Large Business & International Division examination (Exam Team LB&I-NE-TP-2022-00641) challenging transfer pricing methodology for TY 2017, 2018, 2019, 2020; includes IDR responses, functional and economic analyses, formal Protest, and IRS Appeals proceedings
Rate Schedule Effective Period | January 1, 2022 – December 31, 2022
Estimated Total Fee Range (C&H) | $4,500,000 – $7,000,000 (through Appeals resolution)
IRS Examination Opened | May 16, 2022
IRS Form 2848 Filed | June 8, 2022
Kovel Engagement (Expert Consultant) | Whitmore Valuation Group LLC — Kovel letter ref. 1018-00009-KV, executed June 20, 2022; blended rate $650/hr; Lead Economist: Dr. Helena Vasquez
Prepared By | Sylvia Hartwell, Billing Partner
Approved By | Leonard Cross, Responsible Partner
[sheet: Rate Comparison & Blended Rate]
Timekeeper | Classification | 2022 Hourly Rate | Estimated % of Total Hours | Weighted Rate Contribution
Leonard Cross | Partner | $1,475.00 | 15% | $221.25
Sylvia Hartwell | Partner | $1,350.00 | 10% | $135.00
Garrett Simmons | Associate | $885.00 | 35% | $309.75
Leila Nazari | Associate | $695.00 | 30% | $208.50
Paralegals (blended) | Paralegal | $395.00 | 10% | $39.50
TOTAL / BLENDED RATE | 100% | $914.00